About Us
GemsTV Corporate Code Of Conduct
Overview
It is essential that the highest standards of conduct be observed in all contacts made by company employees with customers, shareholders, suppliers, governmental officials, fellow employees and the general public. To further this objective, GemsTV has put together this Code of Conduct to be used in conducting the business affairs of the company.
GemsTV reserves the right to amend, alter or terminate these policies at any time for any reason and without notice.
Application of the code of conduct
It is the policy of the company to comply with all applicable laws; to act fairly, impartially, and in an ethical and proper manner. We expect our employees to do the same. Knowing and intentional violations of these policies may result in disciplinary action, up to and including termination of employment.
Code of conduct
GemsTV is committed to promoting integrity and maintaining the highest standard of ethical conduct in all of our activities. Our business success is dependent on trusting relationships, which are built on this foundation of integrity. Our reputation is founded on the personal integrity of the company's personnel and our dedication to:
- Honesty in communications, both within the company and with our suppliers and customers particularly in relation to our product descriptions;
- Maintaining and protecting the company's and our customers' confidential information and trade secrets;
- Providing first-class quality service to our customers;
- Responsibility for our words and actions;
- Fairness to our fellow employees, customers and suppliers through compliance with all applicable laws and regulations; and
- Respect for our fellow employees, customers and suppliers while showing willingness to solicit their opinions and value their feedback.
Gemstone purchasing
Our customers trust GemsTV to always offer genuine gemstone products. In order to retain this trust, all raw materials, and gemstones in particular, must be authenticated prior to purchase. Based on personal knowledge and/or written guarantees provided by our suppliers, GemsTV guarantees that our gemstones have been purchased from legitimate sources not involved in funding conflict or terrorism. Specifically, any Diamonds purchased must be sourced from legitimate traders not involved in funding conflict and in compliance with the United Nations Resolutions (Kimberley Process). Purchasing managers must take all steps possible to authenticate the origin of gemstones where possible and to ensure purchases are made from known and trusted sources. All purchases must also be properly disclosed to the Anti Money Laundering Office (AMLO) of Thailand as per the current regulatory requirements.
Confidential information
GemsTV believes its confidential proprietary information is an important asset in the operation of its business and prohibits the unauthorized use or disclosure of this information. Our customers often entrust their confidential data to us and employees are prohibited from using or disclosing this information.
To protect confidential information, it is GemsTV's policy that:
- Confidential information of the company or any customer should be disclosed within the company only on a need-to-know basis;
- Confidential information of the company or any customer (paper or electronic) must be marked in accordance with such instructions or other designations as may be required by the company or a customer from time to time;
- Confidential information of the company should be disclosed outside the company only when required by law or when necessary to further the company's business activities and in accordance with the company's disclosure guidelines.
Competitive information
Collecting information on our competitors from legitimate sources to evaluate the relative merits of their products, services, and marketing methods is a necessary part of business life. But there are limits to the ways this information should be acquired. Illegal practices, such as industrial espionage and stealing, are absolutely prohibited. It is also prohibited to seek confidential information in any manner which violates any contractual obligation or commitment. Any form of questionable intelligence gathering is strictly against company policy.
Conflicts of interest
GemsTV employees have an obligation to give their complete loyalty to the best interests of the company. They should avoid any action which may involve, or may appear to involve, a conflict of interest with the company. Employees should not have any financial or other business relationships with suppliers, customers or competitors that might impair, or even appear to impair, the independence of any judgment they may need to make on behalf of the company. Solicitation of vendors or employees for gifts or business favours is prohibited. Therefore, it is company policy that, without full disclosure to, and prior approval of, the Company's Board of Directors, employees may not:
- Perform services for or have a financial interest in a private company that is, or may become, a supplier, customer, or competitor of the company;
- Perform services for or have a material interest (more than 5%) in a publicly traded company, that is, or may become, a supplier, customer or competitor of the company; or
- Perform outside work or otherwise engage in any outside activity or enterprise that may interfere in any way with job performance or create a conflict with the company's best interests.
- Employees are obligated to disclose to their management any situation that presents the possibility of a conflict of interest between the employee and the company. Disclosure of any potential conflict is the key to remaining in full compliance with this policy.
Facilitating payments
GemsTV's objective is to compete in the marketplace on the basis of superior products, services and competitive prices. No payment in any form shall be made directly or indirectly to anyone for the purpose of obtaining or retaining business, or to obtain any other favourable action.
Gifts
No gift should be accepted from a supplier, vendor or customer unless the gift has insubstantial value and a refusal to accept it would be discourteous or otherwise harmful to the company. Employees must receive approval from their management before they accept any gift having a value over US$100.00. This applies equally to giving gifts to suppliers, customers or vendors.
Entertainment
Appropriate business entertainment of non-government employees occurring in connection with business discussions or the development of business relationships is generally deemed appropriate in the conduct of official business. This may include business-related meals and trips, refreshments before or after a business meeting, and occasional athletic, theatrical or cultural events. Entertainment in any form that would likely result in a feeling or expectation of personal obligation should not be extended or accepted. This applies equally to giving or receiving entertainment.
Government representatives
What is acceptable practice in the commercial business environment may be against the law or the policies of federal, state or local governments within the countries we operate. Therefore, no gifts or business entertainment of any kind may be given to any government employee without the prior approval of the Chief Executive Officer.
Agreements with competitors
Formal or informal agreements with competitors that seek to limit or restrict competition in some way are often illegal. Unlawful agreements include those which seek to fix or control prices; allocate products, markets or territories; or boycott certain customers or suppliers. To ensure compliance with antitrust laws in some of the countries in which we operate, discussions with competitors regarding any of these potential agreements is a violation of company policy and may subject the employee to disciplinary action as well as the potential for criminal prosecution.
Employee relations
It is the company's policy that all employees and management, regardless of level, should strive to meet the following objectives:
- Respect each employee, worker and representative of customers, suppliers and contractors as an individual, showing courtesy and consideration and fostering personal dignity;
- Make a commitment to and demonstrate equal treatment of all employees, workers, customers, suppliers and contractors without regard to race, colour, gender, religion, age, national origin, citizenship status, veteran status, sexual orientation or disability;
- Provide a workplace free of harassment on the basis of race, colour, gender, religion, age, national origin, citizenship status, veteran status, sexual orientation or disability;
- Provide a workplace free of any unwelcome sexual advances;
- Afford employees a reasonable opportunity, consistent with the needs of the company, for training to become better skilled in their jobs;
- Encourage promotion from within, consistent with the needs of the company, whenever qualified employees are available;
- Ensure that each manager knows personally every employee two levels directly below them to allow employees an avenue to voice opinions to management other than their direct management.
- Treat any suggestions by external consultants brought in to better our processes as opportunities to improve skills and not as criticism.
- Provide and maintain a safe, healthy and orderly workplace; and
- Assure uniformly fair compensation and benefit practices that will attract, reward and retain quality employees.
Environmental compliance
GemsTV is committed to conducting its business in compliance with all applicable environmental and workplace laws and regulations in a manner that has the highest regard for the safety and well-being of its employees and the general public. Therefore, GemsTV expects all employees to do their utmost to abide by the letter and spirit of these laws and regulations. These laws and regulations must be strictly followed.
Political contributions
It is company policy that, without express prior approval of the Board of Directors, no corporate funds may be used to make political contributions of any kind to any candidate or political party. This prohibition covers not only direct contributions but also indirect assistance or support of candidates or political parties through the purchase of tickets to special dinners or other fund-raising events, and the furnishing of any other goods, services or equipment to political parties or committees.
Charitable donations
The company is committed to providing charitable donations in the communities in which we operate. However, in order to ensure a consistent policy, no corporate funds may be used to make charitable donations of any kind to any charitable organization without express prior approval of the Board of Directors.
Company records
All company books, records, accounts, funds and assets must be maintained to reflect fairly and accurately the underlying transactions and disposition of company business in reasonable detail. No entries will be made that intentionally conceal or disguise the true nature of any company transaction. In this respect, the following guidelines must be followed:
- No undisclosed, unrecorded, or "offbook" funds or assets should be established for any purpose;
- No false or fictitious invoices should be paid or created;
- No false or artificial entries should be made or misleading reports issued; and
- Assets and liabilities of the company shall be recognized and stated in accordance with the company's standard practices and IFRS.
If an employee believes that the company's books and records are not being maintained in accordance with these requirements, the employee should report the matter directly to their manager, to the company's Chief Financial Officer or to the Chief Executive Officer.
Use of company assets
GemsTV's assets are to be used only for the legitimate business purposes of the company and its subsidiaries and only by authorized employees or their designees. This includes both tangible and intangible assets. Some examples of tangible assets include company vehicles and office equipment such as phones, copiers, computers, furniture, and supplies.
GemsTV's email system should be restricted primarily to company business. Highly confidential information should be handled appropriately. Files containing sensitive business data should be appropriately password protected. The company reserves the right at any time to monitor and inspect, without notice, all electronic communications data and information transmitted on the network and electronic files located on personal computers owned by the company or computers on the premises used in company business.
Third party software is provided as a productivity tool for employees to perform their job functions. Employees may be liable as individuals for illegal software use. To the extent permitted under applicable law, employees, contractors and temporary employees shall assign to the company any invention, work of authorship, composition or other form of intellectual property created during the period of employment.
Reporting violations of company policy
There are no easy answers to many ethical issues we face in our daily business activities. In some cases the right thing to do will be obvious, but in other more complex situations, it may be difficult for an employee to decide what to do. When an employee is faced with a tough ethical decision or whenever they have any doubts as to the right thing to do, they should talk to someone else such as their manager, another manager, or the Chief Executive Officer.
GemsTV will not permit any form of retribution against any person, who, in good faith, reports known or suspected violations of company policy.